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RESURRECCION MAKABUHAY,
Respondent
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ANSWER
COMES NOW RESURRECCION MAKABUHAY, by counsel and
unto this Honorable Court, respectfully states and avers that:
1. Defendant admits the allegations contained in paragraphs 1, 2, 3, and
5 of the Complaint;
2. Defendant denies the allegations contained in paragraph 4 of the
Complaint insofar as the period of lease contract is concerned.
Defendant and Plaintif entered into a lease agreement whereby the
Plaintif agreed to rent out her apartment for a period of three (4) years
starting in 01 January 2012. A copy of the Contract of Lease is attached
as Annex 1;
3. For paragraphs 6 and 7 of the Complaint, the Defendant vehemently
denies, the truth being that the latter has religiously paid her monthly
rentals and only missed to deliver the same for the months of
November and December 2014.
4. The Defendant vehemently denies the allegations contained in
paragraphs 8 and 9 of the Complaint; No demands, whether oral or
written, were ever received by Defendant.
5. Insofar as paragraph 12 of the Complaint, the Defendant was never
arrogant during the conciliation proceedings. How can the Defendant
be arrogant when she was new to the community? Furthermore, the
Defendant was willing to settle the case by asking the Plaintif to return
the advance rental and security deposit to which the Plaintif refused;
6. Considering the Defendant having paid the rentals in advance and the
security deposit, Plaintif has no right to evict the former;
damages
in
the
amount
of
PhP
ERNANI T. TADILI
Counsel for the Defense
J.C Aquino St., Butuan City
Tel No. 0922-8766890
Email: etadili@gmail.com
PTR No. 234235/1.5.16/ Butuan City
IBP No. 1231443/12.30.15/Butuan City
Roll of Attorneys No. 86737395/3.15.2010
MCLE Compliance No. V- 13428
TIN 131-0000-13-5
RESURRECCION MAKABUHAY
Affiant
ERNANI T. TADILI
NOTARY PUBLIC
R. Calo St., Butuan City
Commission Serial No. 5637394
Until December 31, 2016
Roll of Attorney
86737295/3.15.2010
IBP No. 1231443/12.30.15/Butuan
City
PTR No. 234235/1.5.16/ Butuan
City
MCLE Compliance No. V- 13428
TIN 131-0000-13-59
Doc. No. 52;
Page No. 89;
Book No. 24;
Series of 2016.
CERTIFICATE OF SERVICE
We certify that on 26th of January 2016, the original of this document
was filed with the Clerk of Court; and, a true and accurate copy of this
document was served on the other party mail, addressed to the
following:
TO: Atty. Juan Tamad
J.C. Aquino Avenue, Butuan City
RESURRECCION MAKABUHAY
Defendant
EXPLANATION